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residence. He eventually sold the residence to a different buyer
in 1994.
As a result of the foregoing events, petitioner divided his
time during 1993 between Nashville and Minneapolis. He reduced
his pilot rank from captain to first officer co-pilot and took a
reduction in salary which enabled him to travel more easily to
Minneapolis. His regular flight schedule during 1993 involved a
short flight from Nashville to Paducah, Kentucky, in the evening,
staying overnight in Paducah at the airline's expense, and a
short flight back to Nashville the following morning. He would
repeat this round trip to and from Paducah three evenings and
three mornings in a row. On the last morning of his weekly
flight schedule, petitioner would take a 3-hour flight to
Minneapolis where he would work for 2 or 3 days for Romer.
During his spare time in Tennessee, petitioner spent a few
hours per week training a horse. He had played polo as a hobby
for many years prior to his relocation to Nashville and believed
that several wealthy polo players in the Nashville area would be
willing to pay at least $40,000 for a properly trained horse.
Petitioner had a horse shipped to Nashville from Minnesota in
January 1993. He did not attempt to train this horse but he did
lease it to other individuals. In May 1993, he purchased a
second horse for $1,300 which he attempted to train as a polo
horse. This horse did not prove to have the athletic ability
required to present it for sale. Petitioner's records show that
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